This started occurring in our testing when the exclusive global locks were removed in dropDatabase() here.
The secondaries oplog can have oplog entries to create the same name but differently capitalized database name prior to running the oplog entry to drop the older database.
In this code, there's a small window between the dropDb() call and creating the oplog entry for secondaries where a create database command on the same name but different capitalization can occur causing the createDb oplog entry to get sent to secondaries before the dropDb oplog entry. The secondary will try to create the database, but will fassert because another database with the same name but different capitalization still exists.